Brown v. State
2025 Ohio 998
Ohio Ct. App.2025Background
- In 1982, Danny Brown was convicted of aggravated murder and sentenced to life in prison; subsequent DNA testing in 2000 excluded him as the source of semen found in the victim, leading to the trial court granting a new trial and the state's dismissal of the indictment.
- Brown was released from prison in 2001 and later sought to be declared a wrongfully imprisoned individual under Ohio law, seeking compensation.
- Brown's first attempt at wrongful imprisonment relief in 2002 was denied on summary judgment, which was affirmed on appeal due to insufficient evidence of actual innocence and the continued existence of Brown as a suspect.
- After R.C. 2743.48 was amended in 2003 and again in 2019 to adjust for "error in procedure" claims, Brown filed new actions under the revised statute, including the case underlying this appeal (filed in 2023), continuing to assert wrongful imprisonment based on his actual innocence and procedural defects.
- The trial court granted summary judgment to the State, finding Brown's latest claims barred by res judicata and collateral estoppel because they had been previously litigated and determined against him.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars Brown's wrongful imprisonment claim | Brown could not previously raise the claim due to legal impossibility; new statute permits claim now | Brown's claims already litigated and decided in prior actions | Res judicata applies; prior decisions bar current claim |
| Whether actual innocence was previously litigated and essential | Actual innocence was not essential to prior judgments, was not fully heard | Actual innocence was litigated and was required under old and new law | Actual innocence was previously litigated, estopping relitigation |
| Whether public interest/fairness justifies relitigation | Fairness and public interest in correcting wrongful imprisonment justify relitigation | No such exception applies; prior decisions should stand | Court rejects fairness/public interest exception |
| Application of 2019 statutory amendments | Amendments permit claim previously barred or appearing futile | Amendments do not override preclusive effect of prior final judgments | 2019 amendments do not allow relitigation of settled claims |
Key Cases Cited
- Goodson v. McDonough Power Equip., Inc., 2 Ohio St.3d 193 (collateral estoppel only applies if identical issue was actually litigated, directly determined, and essential to prior judgment)
- Grava v. Parkman Twp., 73 Ohio St.3d 379 (doctrine of res judicata covers both claim and issue preclusion in Ohio)
- Thompson v. Wing, 70 Ohio St.3d 176 (issue preclusion prevents relitigation of facts and issues already litigated)
- Temple v. Wean United, Inc., 50 Ohio St.2d 317 (sets out summary judgment standard in Ohio)